Investment Policy Statement

The Investment Policy Statement (“IPS”) is the cornerstone of the investment management process. Investment recommendations will be made in concert with the guidelines that Darvas Investment Management LLC (Advisor) and the client agree upon and outline in this document. The IPS opens a channel of communication between us, so that important issues and concerns for either party can be clarified. An effectively developed IPS is the foundation upon which our work together will be based:

1. It establishes the criteria for matching your objectives as the Client to an appropriate investment plan, unless specified to the contrary.

2. It provides a frame of reference that will help keep us focused on long-term (one year or longer) investment objectives. This focus is especially valuable during periods of market volatility when there may be a temptation to react to short-term factors.

3. It establishes the criteria against which progress can be measured.

General Investment Philosophy and Objectives

Consistent with the Client’s investment goals and the Advisor’s investment style and philosophies, the Advisor will achieve performance results via trading as well as a long term investment strategy. Only securities or ETF’s that trade on one of the major exchanges will be used. The Advisor will manage and trade all accounts on a discretionary basis and may go long or short as seems appropriate.

Accounts that cannot legally go short like IRA’s will employ ETF’s when possible to hedge the risk in the portfolio. When a security is bought, all accounts get an equal percentage and the same average price when aggregation is used.

There may be limited diversification in stock positions in which each account may hold less than fifteen stocks at any one time. From time to time, the account may be partially or 100% invested in cash. Darvas reserves the right to vary from the above parameters as market conditions change and as Darvas sees opportunities that may not fit the above criteria.

It is understood that losses may occur in individual securities. The Advisor should adhere to the investment management styles for which they were hired and make reasonable efforts to control risk, recognizing that some risk is necessary to produce long-term results that are sufficient to meet the investment objectives. Short term profitable gains will be subject to short term capital tax rates.

The Advisor may from time to time invest in the same securities as the Client. However, the Advisor may be especially concentrated in only a few securities. The time horizon for the Advisor will always be short-term in nature.

The Client has discussed the various factors that influence your risk tolerance, such as time horizon, financial/tax situation and investment objectives. An understanding of your risk tolerance helps define an investment strategy that you will feel confident maintaining through market ups and downs.

NOTE: Financial markets do fluctuate and there is no guarantee that a certain return will be met, and past performance is not a guarantee of future results.

Time Horizon

Generally speaking, the longer the time frame, the more aggressive the portfolio can be if one wishes to obtain superior returns.

The Advisor currently understands your time horizon to be one to three years.

Investment Policy Review

To assure continued relevance of the guidelines and objectives established in this statement of investment policy, the Client agrees to review the investment policy at least annually.

By committing our agreed upon thoughts to a written document, we minimize the potential for conflict and general misunderstandings. For this reason, we ask you to sign this Agreement to confirm that you concur with its contents. This Investment Policy Statement is meant to be a summary of our agreed upon investment strategy for the management of your portfolio.

Darvas Investment Management LLC is committed to maintaining the confidentiality, integrity and security of the personal information that is entrusted to us.  The categories of nonpublic information that we collect from you may include information about your personal finances, information about your health to the extent that it is needed for the financial planning process, information about transactions between you and third parties, and information from consumer reporting agencies, e.g., credit reports. We use this information to help you meet your personal financial goals.

With your permission, we disclose limited information to attorneys, accountants, and mortgage lenders with whom you have established a relationship. You may opt out from our sharing information with these nonaffiliated third parties by notifying us at any time by telephone, mail, fax, email, or in person. With your permission, we share a limited amount of information about you with your brokerage firm in order to execute securities transactions on your behalf. We maintain a secure office to ensure that your information is not placed at unreasonable risk. We employ a firewall barrier; secure data encryption techniques and authentication procedures in our computer environment.

We do not provide your personal information to mailing list vendors or solicitors.
We require strict confidentiality in our agreements with unaffiliated third parties that require access to your personal information, including financial service companies, consultants, and auditors. Federal and state securities regulators may review our Company records and your personal records as permitted by law.
Personally identifiable information about you will be maintained while you are a client, and for the required period thereafter that records are required to be maintained by federal and state securities laws. After that time, information may be destroyed.

We will notify you in advance if our privacy policy is expected to change. We are required by law to deliver this Privacy Notice to you annually, in writing.

Website Disclosure:

Darvas Investment Management may utilize third party individuals to solicit business, but the individuals may not provide any investment advice or discuss anything other than providing limited solicitation information about Darvas Investment Management. The Chief Compliance Officer is responsible for making sure the content on the website is up to date and correctly represents the firm accurately.